In U.S. v. Smith, 03-13639, the Eleventh Circuit held that "the production of child pornography solely within one state--even with materials that have traveled in interstate commerce--does not have a substantial enough effect on interstate commerce to give rise to federal jurisdiction." The decision created a split with the First Circuit's decision in United States v. Morales-De Jesus, 372 F.3d 6 (2004). Case here and here. U.S. Law Week analysis here. [Mark Godsey]